India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Category: India
India vs SC Lowy P.I. (Lux): International Tax Case
The judgment in SC Lowy P.I. (Lux) S.A.R.L. vs Assistant Commissioner of Income Tax (ACIT) revolved around the denial of treaty benefits under the Dou…
India vs Samsung Electronics: Permanent Establishment Dispute
The High Court of Delhi ruled on appeals filed by the Commissioner of Income Tax (International Taxation) against Samsung Electronics Co. Ltd., challe…
Delhi High Court vs ABIC India Pvt. Ltd: TRANSFER PRICING CASE
The High Court of Delhi, in its judgment dated 14 October 2024, upheld the Tribunal’s decision to reinstate the Transactional Net Margin Method (TNM…
Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases whe…
General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance …
Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multination…
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed …
UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte. Ltd. Case:
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had a "Business…
Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implicati…